Free Motion to Continue Sentencing - District Court of Arizona - Arizona

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16

MICHAEL TERRIBILE 3839 North 3 Street Suite 400 Phoenix, AZ 85012 (602) 254-5544 (602)254-9263 fax State Bar No. 006725 Attorney for Defendant Hudson
dr

IN THE UNITED STATES DISTRICT COURT IN AND FOR THE DISTRICT OF ARIZONA

) ) Plaintiff, ) ) v ) ) ) Danny Lynn Hudson, ) ) Defendant. ) _______________________________ )

United States of America,

Case No. CR04-1065-PHX-DGC

MOTION TO SENTENCING

CONTINUE

Defendant Hudson, through undersigned counsel, respectfully moves

17 this Court to continue his sentencing now scheduled for August 28, 2006, for 18 the reasons stated in the following memorandum. 19

Excludable delay under 18 U.S.C. § 3161(h)(1)(F) may occur as a result

20 of this motion or any order based thereon. 21 22 23

MEMORANDUM Pursuant to the court's most recent order of June 16, 2006, initial

24 disclosure was due to counsel on July 24, 2006, with final disclosure due on 25 August 21, 2006. Counsel received the initial disclosure yesterday, August 26 16, 2006. 27

The Defendant therefore respectfully requests a continuance of the

28 sentencing for an additional thirty (30) days, so he may meet with the

Defendant and go over the presentence report, and file any possible
Case 2:04-cr-01065-DGC Document 83 Filed 08/18/2006 Page 1 of 2

1 2 3 4 5 6 7 8 9 10 11 12 13 14

objections. United States Attorney William Solomon has no objection to this motion. RESPECTFULLY SUBMITTED this 17 day of August, 2006.
ht

s/Michael Terribile MICHAEL TERRIBILE Attorney for Defendant Hudson

15 I hereby certify that on August 17, 2006, I electronically transmitted the 16 and transmittal of a Notice of Electronic Filing to the following CM/ECF 17 sent by e-mail but not filed, to:

attached document to the Clerk's office using the CM/ECF System for filing

registrants with a courtesy copy via e-mail with copies of the proposed order

18 The Honorable David G. Campbell 19 [email protected] 20 William Solomon

U.S. District Court Judge

21 [email protected]

[email protected].

[email protected].

Usa-az-ecf-

22 I hereby certify that on August 17, 2006, a copy was mailed to: 23 Elizabeth Gonshak-Peters 24 401 W. Washington St., SPC 7 25 Phoenix, AZ 85003-2119 26 27 By: s/M. Shepard 28

U.S. Probation Office Suite 160

-2-

Case 2:04-cr-01065-DGC

Document 83

Filed 08/18/2006

Page 2 of 2